NUCLEAR SAFETY STANDARDS

Euratom 96/29/ and the Dangers of Low-level Radioactive Waste
by Hugo Charlton, based on information supplied by the Green Party low-level radiation group

The Green Party claims support for its concern about nuclear safety limits set by the British and international bodies (NRPB & ICRP) following the statement by Dr. Alice Stewart, Honorary Professor of Medicine at Birmingham University, Emeritus Fellow of Lady Margaret Hall, Oxford University and a Fellow of the Royal College of Physicians, that "The UK Government has seriously under-estimated the risks of exposure to radiation".

She went on to say , "These figures [for "safe" levels of exposure] are based largely on studies carried out on survivors of the atomic bombs which were dropped on Hiroshima and Nagasaki, which show there was little long term damage from radiation. I believe these figures are wrong..."

Green scientists are further concerned that a lack of independent scientific scrutiny has allowed bad science and vested interest to cover up real health risks both at home and abroad.

In addition the UK has signed up to EU Directive EURATOM 96/29/ which will be implemented by May 2000. This specifically states that contaminated materials may be reused and recycled into consumer goods of all types whereas that had not been explicitly permitted previously.

Bits of old nuclear plant will turn up in any consumer product - saucepans, toys, belt buckles, bean cans, anything at all. Nobody will know what is radioactive and what is not, and officials will not track or monitor contaminated materials. Radioactive smelter slag will lurk in building materials, tarmac, and playground surfaces. Hot particles from landfill dumps, and radioactive ash from unregulated incinerators will pollute the air. Even our food is at risk, as radioactivity will be added to fertilizers. This is already being done in the USA.

To make matters worse, the permitted levels would be raised allowing for contaminated material thousands of times higher than the present UK limit of 400 Bq/Kg. It is said to be safer because some EU counties have little or no limits at the present, but as far as the UK is concerned it makes matters much worse. This is because the present UK limit of 400 Bq/Kg applies to all types of radiation, whereas the new limits make distinctions for different types of radiation whose limits are to be far more dangerous.

Thanks to pressure from the Green Party Michael Meacher is seeking to persuade his colleagues to leave the UK levels as they are, which means no change to the Radioactive Substances Act 1993, but although this is reflected in the consultation document it is not stated in the new legislation so the pressure must be retained. The nuclear lobby will continue to seek laxer regulations, as they have for a long time. This is because for the first time there is large-scale decommissioning of nuclear plants, which will generate millions of tonnes of contaminated materials and the industry would like to make money from selling it and at the same save themselves the cost of safe disposal.

Some of the radioactivity will inevitably become incorporated into consumer goods and food. The nuclear industry claim it is safe to expose people to ingesting radioactive substances in this way because the levels will be diluted. But radioactive dust or particles do not dissolve like liquid, it is like saying one radioactive pea in a can will become safe if it is "diluted" in a huge can of thousands of peas. Of course it won’t, but there will be less chance of you eating it. It’s like mincing BSE-infected cows and putting a little into everyone’s food.

Another argument is that man-made radioactivity is no different from natural background radiation, whereas in fact there are entirely new isotopes different from the radioactivity with which life on Earth evolved. Moreover the biological behaviour is ignored, for example no weight is attached to the fact that Strontium 90 is chemically attracted to the lactose in the mammary glands. Worst of all, they leave undone the research which would identify the most dangerous isotopes and just how they cause genetic damage. A medical practitioner was only included on the board of the NRPB for the first time last year.

And remember, products containing higher levels of radioactivity than would be allowed to be produced here can be imported from the rest of Europe.

There’s now a mass of evidence linking genetic damage with low doses of radioactive pollution. For example: High mortality from breast cancer among women living downwind of nuclear sites and among women whose breasts were developing when nuclear bomb fallout was at its peak; Trends in bomb test fallout are echoed in cancer incidence trends some 20 years later; Clusters of cancer and leukaemia near most nuclear facilities; More infant leukaemia after the Chernobyl accident; Fewer babies born alive after Chernobyl; Raised rates of genetic mutation in areas contaminated by Chernobyl; Growing numbers of very low birth-weight babies.

ALL UNEXPLAINABLE UNDER CURRENT NRPB "SAFETY" LIMITS

Radioactive emissions are allowed because NRPB claim the levels of radiation dose are too low to cause such effects. But their assessment of risk is deeply flawed. It is based on the false assumptions that internal and external radiation affect health in the same way, many studies show this is not true. The Hiroshima controls (i.e. the population who provide the baseline for estimating how much disease was caused by the bomb) were not exposed to radiation- in fact the "unexposed" controls and the "exposed" study population all lived in the city and ate, drank and breathed fallout month after month, so even the "control" population was contaminated which meant the seriousness of the exposure was underestimated. This scientific evidence has been presented in a court of law and remained unchallenged, but it did emerge that Dr Peter Iredale, the man who is now in charge of the Oxfordshire Health Authority, which refused to release cancer statistics which would have supported Green Party scientists giving evidence, had been until 1992 Director of Harwell, the nuclear weapons research establishment! So that it could be said that the man most responsible for causing cancer in Oxfordshire was now responsible for suppressing the very statistics which might incriminate him.

Cancer near the Irish Sea Since 1952 BNFL’s reprocessing plant at Sellafield has polluted the sea with radioactivity (including two or three tons of Plutonium) which contaminates seafood as far away as the Baltic and the Barents Sea. It is migrating back onto the shore and can be detected miles inland. From the Dee to Pembrokeshire children under the age of 4 who live within a mile of the sea are 2½ times more likely to have cancer than children who live inland. The risk falls off with increasing distance from the sea. The same effect is seen in all age groups and for nearly all types of cancer.

High rates of leukaemia are found near Morecambe Bay, in Dumfries and Galloway in Scotland, and in the Irish fishing ports of Dundalk and Carlingford. The highest risks are near estuaries, where radioactivity is known to concentrate. The officials in Wales responsible for cancer data have admitted losing the figures which made the Welsh research possible. The UK Environment Minister has referred it to COMARE (Committee on Medical Aspects of Radiation in the Environment).

Linda McCartney may be Sellafield’s most famous victim. She and her husband, the Beatle Paul McCartney, had a farm on the Mull of Kintyre - directly in the stream of radioactive waste heading for the Arctic. She died of breast cancer in 1998.

DETAILS OF THE EURATOM DIRECTIVE

Directive 96/29/EURATOM sets out to harmonise all aspects of radiation protection standards. The EU requires it to be transposed into domestic law in member states by 13th May 2000. Since this is a time of crisis for the science underlying the standards embodied in the Directive, two aspects of it give great cause for concern:

The "exemption" provisions empower member states to permit some businesses to use and dispose of radioactivity without reporting or being authorised. "Exemption" was originally intended to allow businesses (and Universities, laboratories etc.) using small amounts of radioactivity to function "without burdensome regulation" i.e. without entering the regulatory system. But this part of the Directive is vaguely drafted; it makes no mention of the scale of undertakings, and allows unlimited amounts to be used and discharged to the environment unregulated, the only condition being that threshold values for the concentration of radioactivity are not exceeded. The Directive lays down widely varying thresholds (or "Exemption Values") which are between 2.5 times and 2.5 million times higher than current Exemption Value in the UK. Both the concept of Exemption itself and the Exemption Values to be applied are at the discretion of member states, but the draft revision of the UK's Ionising Radiation Regulations faithfully reproduces the conditions and values suggested in the Directive.

Following meetings with the Green Party, the UK's Department of the Environment, Transport and the Regions has told us that the UK's existing Exemption Value will be retained, unless there are compelling arguments for change.

The "clearance" provisions of the Directive continue to give concern. The idea of Clearance means that below certain thresholds ("Clearance Levels"), contaminated materials arising from dismantling nuclear licensed sites can be sold on the open market. Unsaleable materials below the Clearance Levels will be land filled and incinerated without restriction. The OECD estimates that in the next few decades dismantling hundreds of nuclear factories and power stations will generate 30 million tonnes of metals alone, and assesses its worth at 10 15 billion dollars. With disposal of all wastes becoming more contentious and expensive there is a double incentive for contaminated materials and wastes to be classified as "safe". The Clearance provisions are permissive and badly drafted (even the Commission admits that this part of the Directive is "rather difficult to read").This led to wild enthusiasm within the industry that "new standards for de minimis would be of considerable assistance to decommissioning." After this Campaign drew public and media attention to the Directive the Commission published a Guidance Note setting lower thresholds than the industry expected, and preventing "hot" materials being diluted to achieve Clearance.

The Directive specifically allows reuse, recycling, disposal, and incineration of cleared radioactive materials. Spokesmen from the nuclear industry, the regulators, and the Commission openly admit that there is nothing to stop the radioactivity ending up in consumer goods, fertilisers or any product. There will be no tracking, and the Commission's view is "Let the buyers beware if they don't want contaminated goods or raw materials." Both the concept of Clearance itself and the Clearance Levels to be applied are at the discretion of member states. However, member states which set restrictive or nil Clearance Levels will not be able to prevent importation of contaminated wastes and goods and materials from less responsible countries.

Clearance will lead to widespread dispersion of radioactivity, exposing the maximum possible number of people. This is admitted by the Commission. They claim that, according to internationally accepted radiation risk factors, it represents a trivial and acceptable health risk. But neither the total risks nor the supposed benefits have been quantified as required by EU law on Justification of radioactive practices.

The International Commission on Radiological Protection (ICRP) sets the standards. From its inception, both the personnel and the work of ICRP were heavily influenced by the nuclear industry and the politics of nuclear confrontation. Their membership overlaps with that of their clients, the national agencies (e.g. UK's National Radiological Protection Board). Their impartiality is in doubt and the underlying science is demonstrably unsafe; the studies of Japanese A-bomb survivors, on which they rely heavily, are completely silent about risks from internal radiation from manmade isotopes. NRPB (the most influential of ICRP's satellites) plays down uncomfortable evidence and has lied to the British Government in an effort to avoid awkward questions.

In the late 1950s Nobel laureates Linus Pauling and Andrei Sakharov predicted disastrous consequences from radioactive pollution of the environment, and there is now plentiful evidence that genetic damage from weapons-testing fallout is the major cause of the current worldwide cancer epidemic. The vulnerability of the human genome to low levels of manmade radioisotopes can be seen in increased leukaemia incidence next to the Irish Sea the world's most radioactive sea. The scale of the error in ICRP risk factors can be calculated from increases in infant leukaemia after Chernobyl. The world community of radiation biologists is in open and growing discord. Some scientists are saying that the human gene pool is being permanently polluted. When such doubts are being expressed it is inexcusable to allow a new wave of radioactive contamination; some environmental and criminal lawyers are of the opinion that those responsible may be liable to criminal prosecution for occasioning actual bodily harm Radioactive materials should be prevented from escaping into the biosphere. Contaminated waste should be stored in retrievable form, monitored, and repackaged as necessary. The Green Party, in consultation with Greenpeace, Friends of the Earth, the Campaign for Nuclear Disarmament, and elected representatives and environmental and ethical organisations across Europe, is taking the lead in a campaign to prevent implementation of the Directive's worst aspects.